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Are You A Money Transmitter In Florida?

The Florida Office of Financial Regulation (“OFR”) has rejected a petition for a declaratory statement seeking confirmation that payment processing activity involving the receipt of funds and transmission of such funds does...more

FinCEN Seeks To Expand Scope Of Information Collection And Recordkeeping Requirements For Money Transmitters And Other Financial...

A new proposed rulemaking (the “NPRM”) would lower the current $3,000 threshold for the applicability of the Bank Secrecy Act (“BSA”) Recordkeeping Rule and Travel Rule to $250 for covered funds transfers that begin or end...more

Bitcoin Is “Money” For Purposes Of D.C. Money Transmission Law, Says Federal Court

A recent federal district court ruling in a criminal anti-money laundering case suggests that the transmission of virtual currency on behalf of another person requires a state money transmission license—even if the state’s...more

Are You A Money Transmitter In South Dakota? In Delaware?

One of the defining aspects of the payments revolution of the past few years—at least from a regulatory perspective—has been the question of whether a particular payments service is subject to regulation as money...more

Are You A Money Transmitter In Massachusetts? In Rhode Island?

As we enter 2020, the payments and money transmission regulatory landscape continues to evolve on a state-by-state basis. One key development to kick off the year is newly adopted regulations in Massachusetts affirming that...more

Take Two: Are You a Money Transmitter in Vermont?

Last year, we noted that the Banking Department of the Vermont Department of Financial Regulation had taken the position that its money transmission law “does not exempt a payment processor or an agent of a payee from [money...more

Are You a Money Transmitter in Michigan? In California?

The payments and money transmission regulatory landscape continues to evolve. A key new development is that Michigan has affirmed by legislation that “agent of a payee” transactions meeting certain criteria are not subject...more

Are You a Money Transmitter in California?

As we have noted on multiple occasions, one of the most important questions in the non-bank payments revolution — at least from a regulatory perspective — is whether a particular payments service is subject to regulation as...more

Are You a Money Transmitter in Vermont?

The Banking Department of the Vermont Department of Financial Regulation (the “Banking Department”) recently entered into a consent order with a money transmission licensing applicant (the “Applicant”). The consent order...more

Are You a Money Transmitter in Connecticut? In Hawaii?

As we have noted previously, one of the defining aspects of the payments revolution of the past few years—at least from a regulatory perspective—has been the question of whether a particular payments service is subject to...more

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